NASNA outlines ‘strong and urgent concerns’ about NG911 funding language in spectrum bill
Legislation before the U.S. Senate that would allocate as much as $10 billion in federal funds for next-generation 911 (NG911) deployment includes language that “will unnecessarily detract from and delay NG911 implementation,” according to a letter from the National Association of State 911 Administrators (NASNA).
Under H.R. 7624—the version of the “Spectrum Innovation Act” approved last month by the U.S. House with bipartisan support—the FCC would be required to conduct an auction of at least 200 MHz of spectrum in the 3.1-3.45 GHz band. Proceeds from the auction would be used to address the $3.4 billion shortfall in the FCC’s “rip and replace” program that is designed to rid U.S. commercial networks of “untrusted” equipment and then as much as $10 billion would be dedicated to funding the NG911 transition at 911 centers throughout the U.S.
NASNA’s 48 member-states “support the premise of H.R. 7624,” but they “have concerns that the admirable goals set forth in the bill itself may not be fully realized in its current form,” according to the letter, which is dated Aug 24 and was posted on the NASNA web site yesterday.
“NASNA was a contributing member of the original public safety community that developed the base language of earlier iterations of the NG911 funding bill,” the letter states. “NASNA supported that initial language, and we still support the premise of federal assistance for NG911. However, we believe now is the time to voice our strong and urgent concern about this current version of the legislation.
“We are fully aware that there have been matters raised by other public-safety groups and we are concerned that these other interests will unnecessarily detract from and delay NG911 implementation.”
Written by NASNA Executive DIrector Harriet Rennie-Brown, NASNA’s letter does not identify these other public-safety groups, but the letter was written just days after the Public Safety Next Generation 911 Coalition—a group of several public-safety associations—released its letter to the Senate seeking $15 billion in funding, instead of the $10 billion that is included in the current bill.
In addition, the coalition asked that the National Telecommunications and Information Administration (NTIA) be allowed to borrow funds immediately, as opposed to waiting for the FCC auction to be completed—a process that could take several years—to initiate the proposed grant program.
NASNA does not believe that the NTIA should be the sole agency administering the proposed NG911 grant program, according to the letter. Instead, it would like the current National 911 Program—a joint office of the NTIA and the National Highway Traffic Safety Administration (NHTSA)—to maintain its role.
“While NASNA understands that there is a desire by some to place all 911 grant oversight and operational /technical
support services under the single umbrella of NTIA, NASNA believes this move is premature and overlooks the vital role NHTSA plays in the 911 environment,” the NASNA letter states.
“NASNA believes changing the current programming without a sound evaluation will impede the forward progression of NG911 for all states, regardless of the NG911 deployment status.”
In its letter, NASNA also opposes language in H.R. 7624 that would “establish a Nationwide Next-Generation 911 Cybersecurity Center,” describing such a center as being “redundant and unnecessary,” given the existing cybersecurity landscape for 911.
“States already individually have been and will continue to make determination on the proper security of NG911 systems,” according to the NASNA letter. “The FCC’s Taskforce on Optimal PSAP Architecture (TFOPA) provides a framework for NG911 cybersecurity at the state, regional and local levels.
“In regard to federal NG911 cybersecurity support, there already exists an active and vital resource for NG911 within CISA at DHS. CISA is actively engaged with the needs of the NG911 community and has been providing support and resources to 911 for years … Rather than creating a second national NG911 cybersecurity center, any funds allotted by H.R. 7624 for this purpose could be directed to CISA to support the NG911 cybersecurity programming already in place. A duplicative cybersecurity center at NTIA is not necessary and attempts to solve a problem that simply does not exist.”
NASNA also reiterated that it “fully supports” i3, the IP-based network architecture for NG911 developed by the National Emergency Number Association (NENA) that was accredited by the American National Standards Institute (ANSI) last year.
“While we support innovation and competition, we do not support any amended language that would give preference to an alternative standard,” the NASNA letter states. “Every state, regional and local agency that is implementing NG911 is based on the NENA i3 standard.”
Finally, NASNA expressed distastes for the state NG911 plans that are required in the bill that passed the House, describing the requirement as “barriers to assistance” for states seeking federal funds to pay for upgrades to the 911 system.
“It is ultimately the states that will coordinate and implement NG911 across the country, and we each have a unique perspective on what is needed to be successful in our individual states,” according to the letter, which emphasized the final three words of the sentence.
“We believe that the overly prescriptive conditions written into H.R. 7624 for the states’ NG911 plan are redundant, unnecessary and create burdensome requirements for the states’ 911 systems. The NG911 plan requirements are best suited to the grant-rulemaking process, not congressional mandates.”
In its letter, NASNA describes the proposed $10 billion in federal funds for NG911 deployment as “significant,” noting that the money would be a “great financial assistance to move NG911 forward” throughout the country.
NASNA’s letter does not address the Public Safety Next Generation 911 Coalition’s request for $15 billion, nor does it directly address the coalition’s call for immediate borrowing authority. However, the NASNA letter does indicate that timely access to federal funding is important for the proposed legislation to be effective in supporting NG911 deployments.
“If the funding is quickly accessible, usable and works effectively with the systems that we are already building—we welcome the opportunity,” the NASNA letter states.
NASNA’s input on H.R. 7624 comes as lawmakers soon are scheduled to return to Capitol Hill during a potentially critical juncture, as the current session of Congress approaches its final stretch and many members are running for re-election in November.
If it wants to pass the Spectrum Innovation Act before the FCC auction authority expires on Sept. 30, the Senate will have 19 business days under the current schedule to move the legislation through the committee process, conduct a floor vote and—if necessary—complete any conference-committee work. If there is a desire to have President Joe Biden sign the bill into law by Sept. 30, that timetable would need to be accelerated.
However, there may not be an urgent need to extend the FCC auction authority by the Sept. 30 expiration date, given that the 2.5 GHz auction was completed this week.
If the Sept. 30 date is not significant to lawmakers, the Senate has nine business days scheduled in October before the mid-term elections. After the election, the Senate is slated to work for 23 days before the session ends.
Any legislation that does not pass by the end of the session would have to be reintroduced in the next Congress for consideration.